Is a district court deciding not to grant a post-sentence reduction under 18 U.S.C. § 3582(c) in proportion to the amended Federal Sentencing Guidelines required to provide an explanation, or is no explanation necessary so long as the court uses a preprinted form order that provides a policy statement and certifies the applicable sentencing factors?
The Supreme Court will decide whether a court, in deciding not to grant a discretionary post-judgment sentencing revision under 18 U.S.C. § 3582(c)(2) in proportion to the amended Federal Sentencing Guidelines, must provide an explanation or can issue its decision through a preprinted form order containing standardized language. The Fourth, Fifth, and Tenth Circuits have held that § 3582(c)(2) does not require a judge to provide an explanation when refusing to grant a motion for a proportional sentencing reduction in accordance with the amended Guidelines. The Sixth, Eighth, Ninth, and Eleventh Circuits, however, have found that judges are required to explain sentencing revision decisions. Petitioner Chavez-Meza argues that a judge must provide some explanation for a disproportional sentencing reduction when the reasons for the decision are not apparent from the record. Respondent United States argues that judges can use preprinted forms when granting sentencing revisions that are disproportional to the Guideline revisions, as long as the form order contains standardized language stating that the court has considered the policy and applicable factors set forth in 18 U.S.C. § 3553(a). This case will clarify the extent to which application of the amended Guidelines reflects a bipartisan shift away from punitive sentences for drug offenses.
Questions as Framed for the Court by the Parties
Whether, when a district court decides not to grant a proportional sentence reduction under 18 U.S.C. § 3582(c)(2), it must provide some explanation for its decision when the reasons are not otherwise apparent from the record, as the U.S. Court of Appeals for the Sixth, Eighth, Ninth, and Eleventh Circuits have held, or whether it can issue its decision without any explanation so long as it is issued on a preprinted form order containing the boilerplate language providing that the court has “tak[en] into account the policy statement set forth in U.S.S.G. § lBl.10 and the sentencing factors set forth in 18 U.S.C. § 3553(a), to the extent that they are applicable," as the U.S. Courts of Appeals for the Fourth, Fifth and Tenth Circuits have held.
Following an investigation and sting operation in 2012, federal authorities arrested Petitioner Adaucto Chavez-Meza on charges of conspiring with the Sinaloa Cartel to distribute methamphetamine in the United States.
Jody Godoy, Judges to Weigh Resentencing Under New Guidelines, Law360 (January 16, 2018)